PASFAA Annual Conference October 2012

1. PASFAA Annual ConferenceOctober 2012 Campus-Based Programs: Awarding/Disbursing/Reporting – Tips, Reminders and Insights

2. Campus-Based Programs *********** Awarding Aid

3. Awarding FWS • Must be made reasonably available to all eligible students • No award limits but may not exceed need • Student’s academic workload should be considered • Net earnings should be used for awarding and packaging • Gross amount excluding job-related expenses and non-refundable taxes

4. FWS - Periods of Non-Attendance • Student may be employed during periods of non-attendance • Summer, vacation, period of co-op education or unattended term • Student must be planning to enroll for the next period of enrollment • Financial need must exist for that period • Net earnings must be used to cover expenses related to financial need for that period

5. FWS: Period of Non-Attendance – Failure to Return • School must be able to demonstrate: • Student was eligible for employment • School had reason to believe, at the time FWS was awarded, that student would return • Documentation • Written record showing student’s acceptance of offer of admittance for next period • Student must immediately cease FWS employment if, during period of non-attendance, school learns student will no longer enroll for the next period of enrollment

6. FWS and Modules • School combines modules into a term • FWS student attending any module may earn FWS throughout the term • Earnings may be applied toward financial need for the mini-session attended and/or the next period of enrollment • Financial need must be based on the period when student is actually enrolled in modules

7. Awarding FSEOG • Award cannot exceed minimum/maximums • Minimum - $100 • Maximum - $4,000 • Up to $4,400 in a study abroad program

8. Awarding FSEOG • Pell Grant recipients with lowest EFCs • Known as FSEOG first selection group • Not necessary to receive a Pell Grant in the same payment period as FSEOG • Must be received in same award year • Example: student only receives Pell Grant in Fall due to reaching Pell LEU • Not receiving Pell Grant with lowest EFCs • Known as FSEOG second selection group • May be selected after all Pell recipients have been awarded • Includes students who exceed Pell LEU for entire award year

9. Awarding FSEOG • Establishing categories of students • Selection procedures may establish categories of students • Class standing, enrollment status, program, etc. • May assign a percentage or dollar amount of funds to each category • May not be used to exclude certain groups • Within each category must first award to Pell recipients, lowest EFCs • Funds must be made reasonably available for all starts in an award year (subsequent terms or payment periods)

10. Awarding FSEOG • Selection Prohibitions • Awarding on a first-come, first-serve basis • Arbitrary EFC benchmarks (cut-offs) • Use of professional judgment in awarding • Applicable only to making adjustment(s) to a data element(s) in the EFC or COA • May not be used to circumvent selection priority • Awarding to offset loss of Pell Grant eligibility due to LEU

11. Awarding FSEOG • Crossover payment periods • If receiving Pell during a crossover payment period and among lowest EFCs, student meets first selection group requirements • Receiving FSEOG but not Pell during crossover period, in first selection group (either award year’s allocation) IF: • Student will receive a Pell Grant in the award year to which payment period is assigned

12. Awarding Perkins Loans • Maximum loan amounts • Per award year • $5,500 undergraduate • $8,000 graduate/professional • Aggregate (unpaid principal) • $11,000 any student who has not completed 2 years of undergraduate study • $27,000 undergraduate who has completed 2 academic years and is pursuing a bachelor’s • $60,000 for a graduate

13. Awarding Perkins Loan • Perkins selection criteria • Priority given to students with exceptional need as defined by the school • Pell grant eligibility must be determined first • Selection procedures must be in writing, uniformly applied and kept on file

14. Disbursing Campus-Based Funds

15. Disbursing CB Awards • $200 limit on prior award year charges that may be paid from current year CB funds • EFT may be made without student authorization • Student may refuse but must still be paid • Payment may be issued to stored-value card • School must obtain student authorization to credit FWS to student’s account at institution

16. Disbursements – FSEOG & Perkins • Award amount divided by the number of payment periods expected to attend in the academic year • May receive uneven amounts each payment period to cover uneven costs or EFA

17. Disbursing FWS Wages • School has a choice of payroll period • Students must be paid at least monthly • FWS earned when students perform work • Wages earned while attending may be paid after the last day of attendance • FWS may not be paid for work performed after student withdrew (if not planning to return)

18. Disbursing FWS Wages • Crossover Payment Periods • Compensation earned through June 30 is paid with funds allocated for first award year • Compensation earned starting July 1 is paid with funds allocated for the following year • Choice of EFC (must be same as for CB/DL) • Holding FWS Funds for the Student • Requires written authorization • Amounts must be identified in subsidiary ledger • Cash equal to amount being held must be maintained • Remaining amount must be disbursed by end of the final payroll period for the award year

19. Disbursing FWS Wages • FWS students may be paid overtime in accordance w/applicable labor rules • FWS wages may not be paid for hours worked during scheduled class time • FWS earnings may only be garnished to pay costs of attendance the student owes the school during the period of the award • School must oppose all other garnishment orders • School must inform all off-campus employers that wages may not be garnished

20. FWS Payments: Disaster Affected Students • School in a major disaster area (FEMA designated) may make payments to affected students for a period of time when they were unable to fulfill work obligations • Period may not exceed one academic year • Payments may be = or < than amount they would have received if working • Payments may not be made to students not eligible for FWS or completing a work obligation prior to disaster

21. Campus-Based Funds: Transfers & Carry Forward/Back

22. Fund Transfers Flexibility to transfer funds between programs under certain circumstances • FWS • May transfer up to a total of 25% of its federal FWS allocation (initial plus supplemental) for an award year to its revolving Perkins fund or federal FSEOG allocation, or both • Does not need to receive Perkins FCC but must have a Perkins Level of Expenditure (LOE)

23. Fund Transfers • FSEOG • A school may transfer up to 25% of its federal FSEOG allocation to its federal FWS allocation • Perkins* • Since no Federal Capital Contribution available, no ability to transfer funds to other programs

24. Fund Transfers: General Rules • Award transferred funds according to the requirements of the program to which they are transferred • Report the transfer of funds on the Fiscal Operations Report portion of the FISAP • Any transferred funds that are unexpended must be transferred back to the original program at the end of the award year • The program that the school wants to transfer funds to must also have an allocation for that same award year

25. Carry Forward • May spend up to 10% of its current year’s FWS or FSEOG allocation (initial and supplemental) in the following award year (carry forward) • Before a school may spend its current year’s allocation, it must spend any funds carried forward from the previous year

26. Carry Back • Your school is also permitted to spend up to 10% of its current year’s FWS or FSEOG allocation (initial and supplemental) for expenses incurred in the previous award year (carry back)

27. Carry Forward/Carry Back • FWS Limitations: • Not permitted to add funds that are carried forward or back to the total FWS allocation for an award year when determining the maximum percentage of available funds that may be used in that award year for – • Transferring FWS funds to FSEOG • Providing the federal share of wages in private for-profit sector jobs; • The Job Location and Development (JLD) Program

28. Carry Back for Summer • May use any portion of initial/supplemental FWS allocations for the current award year to pay student wages earned on or after May 1 of the previous award year but prior to the beginning of the current award year • May spend any portion of its current award year’s initial/supplemental FSEOG allocations to make FSEOG awards to students for payment periods that begin on or after May 1st of the prior award year but end prior to the start of the current award year

29. Carry Forward/Back: General Rules • Must match FWS or FSEOG funds carried forward or carried back in the award year that they are spent • Report funds carried forward/back on the FISAP • May not carry forward or carry back any funds to any award year in which there is no specific program allocation • Not permitted to add funds carried forward or back to the total FWS or FSEOG allocation for an award year when determining the maximum percentage of available funds that may transfer

30. G5 Issues • CB funds transferred from one program to another must be entered in G5 as an expenditure against the program from which they were transferred. • FWS or FSEOG funds carried forward or back must be entered in G5 as an expenditure against the authorization for the award year from which they were taken • Do not attempt to transfer CB funds in G5

31. Matching Requirements

32. Federal Share Limitation • FWS Limits • In general, the federal share of FWS wages paid to a student may not exceed 75% of the student’s total wages • If student working for a private for-profit organization, the federal share of the student’s wages may not exceed 50%

33. Federal Share Limitation • FWS Limits: • May use the federal share to pay up to 100% of the FWS wages paid to a student who is - • performing civic education and participation activities in community service projects, • employed as a reading tutor for preschool-age children or elementary school children, • employed as a mathematics tutor for children in elementary school through ninth grade, • performing family literacy activities in a family literacy project that provides services to families with preschool or elementary age children.

34. Federal Share Limitation • FWS Limits: • May use the federal share of FWS wages to pay up to 90% of a student’s wages if: • Student employed at private nonprofit organization or federal/state/local public agency • School does not own, operate, or control the organization or agency • The school selects the organization or agency on an individual, case-by-case basis • Entity unable to pay the regular nonfederal share • 90% federal share is limited to no more than 10% of the students paid under the FWS Program

35. Federal Share Limitation • FSEOG Limits • The federal share of FSEOGs made by a school may not exceed 75% of the total FSEOGs • Perkins Limits* • Congress has not allocated any Federal Capital Contributions in several years

36. NonFederal Share: FWS • Nonfederal share of a student’s FWS wages must be at least 25% each award year (unless specific exception noted) • School’s share may come from its own funds, from outside funds, or from both. • If a student is employed by a private, for-profit organization, that organization must provide the nonfederal share • School may also pay the institutional share with noncash contributions

37. NonFederal Share: FSEOG • The 25% nonfederal share of FSEOGs made from the school’s own resources (unless received a waiver) may include: • institutional scholarships and grants; • waivers of tuition or fees; • state scholarships and grants; and • funds from foundations or other charitable organizations

38. FSEOG Matching Options • (1) Fund-Specific basis • School establishes FSEOG fund into which it deposits FSEOG federal funds and the required 25% nonfederal share • Awards are made from the fund Example: FSEOG allocation is $57,000, total available for awards* $76,000, nonfederal share is $19,000 Both the federal and nonfederal share are deposited into the FSEOG fund as required for disbursing awards * Assumes no ACA taken from FSEOG

39. FSEOG Matching Options • (2) Individual recipient basis • School provides its share to an individual recipient together with the federal share • Each student’s total award consists of 25% nonfederal resources and 75% federal dollars Example: Fred the Student is awarded $1,000 of FSEOG His individual award consists of $250 in state grant funds and $750 in federal dollars

40. FSEOG Matching Options • (3) Aggregate basis • School ensures sum of all funds awarded comprises 75% FSEOG funds and 25% nonfederal resources • Each recipient must receive some FSEOG funds Example: FSEOG allocation is $57,000, total available for awards* $76,000, nonfederal share is $19,000 School will match using state grant funds $1,000 is posted to the accounts of 57 recipients School must ensure recipients received state grants in an amount necessary to meet required $19,000 nonfederal share *Assumes no ACA taken from FSEOG

41. NonFederal Share Waiver • ED may waive the nonfederal share requirement for FSEOG and FWS for a school designated as an eligible school under 34 CFR parts 606, 607, 608 or 609 (FWS only) • Under FWS, the institutional share requirements for employment provided by a private for-profit organization or the administration of the JLD Program are never waived

42. NonFederal Share: Perkins • Perkins • Nonfederal share is called Institutional Capital Contribution (ICC) • Since Congress has not allocated any Federal Capital Contribution, there is currently no ICC requirement • However - school may elect to make its own contributions to the Perkins revolving fund

43. FWS: Use of Funds Stipulations

44. Releasing Unused Funds • If school returns more than 10% of its allocated funds for any CB program, ED will reduce allocation for second succeeding year by the amount returned • ED may waive upon request • Waiver is requested when FISAP is filed by submitting an explanation per FISAP Instruction Booklet • Must be a circumstance beyond the school’s control

45. FWS Use of Funds Tips • Are we avoiding penalty for underuse of funds? • Do not request more funding than can be used • Transfer funds to FSEOG • Carry-forward • Take Campus-Based ACA from FWS • Up to 10% or $75,000 of FWS allocation may be used for job location and development under the JLD program

46. Reallocation • Reallocation form (www.cbfisap.ed.gov ) must be completed in the following situations • School will not spend entire 2011-12 FWS allocation • School is requesting supplemental 2012-13 FWS funds to pay students in community service jobs • Must have spent at least 5% of 2011-12 allocation to pay students employed as reading tutors of children or in family literacy activities as part of community service • Must have an FWS fair share shortfall as shown on line 28 of the 2011-12 final allocation letter • August 17, 2012 deadline

47. Special FWS Allocation Requirements • Community service expenditure obligations: • Must use at least 7% of its FWS federal allocation for an award year to pay the federal share of wages to students employed in community service jobs for that year • One or more of the school’s FWS students must be employed as a reading tutor for children in a reading tutoring project or performing family literacy activities in a family literacy project.

48. Special FWS Allocation Requirements • Community service expenditure waiver: • May request a waiver of one or both of the community service expenditure requirements by the annual deadline • Electronic announcement comes out in March with submission due date in April • The school should include detailed information that demonstrates that the requirement would cause a hardship for students at the school

49. FWS Use of Funds Tips • Are we meeting 7% community service requirement? • Adjust pay rate for community service jobs where warranted • Jobs requiring certain skills may merit more than minimum wage • Allocate more than 7% to ensure threshold is actually met • Jobs assisting students with disabilities are considered community service • Certain jobs in tutoring/family literacy and civic education can be community service and allow 100% Federal share of wages • Is as least one student employed as a reading tutor/family literacy project?

50. FWS: General Employment & Community Service Requirements